Inconsistent grounds in 148A notices deprived assessee of fair opportunity; HC quashed reassessment proceedings.

The High Court quashed reassessment proceedings due to inconsistent grounds in notices issued under sections 148A(b) and 148A(d). The Assessing Officer initially made certain allegations in the 148A(b) notice, but later raised different grounds in the 148A(d) order. This inconsistency deprived the assessee of a fair opportunity to address the claims, as the alleged escaped income had been previously disclosed and assessed. Consequently, the court set aside both the 148A(b) notice and the 148A(d) order. .....

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